AG Seeks Investigation Of Future Of Gas Utilities, Supply In Retail Choice State; Specifically Implicates "Diversification", "Expansion" Of Gas Utilities' Business Operations To Meet GHG Goals

The Massachusetts Office of the Attorney General petitioned the Department of Public Utilities to initiate an investigation to assess the future of local gas distribution company ('LDC') operations and planning in light of the Commonwealth’s legally binding statewide limit of net-zero greenhouse gas ('GHG') emissions by 2050.

In doing so, the AG asked that the DPU consider, among other things, "Should shareholders pay for the diversification and expansion of the LDC’s business operations to meet GHG emission limits?"

"How should the Department determine what is business expansion vs. the provision of a monopoly service that is recoverable in rates," the AG proposed as a question for the investigation

The AG's petition also implicated green gas supply, which is currently a value-added product at most LDCs

The AG proposed consideration of the following issues:

• Renewable Natural Gas - Biofuel ('RNG'): What is the potential for RNG to meet future gas demand and deliver verifiable GHG emissions reductions? Is RNG readily available? What considerations are there for scalability and associated operational costs? What infrastructure investment is required to support the widescale use of RNG? What policy or legislative action might be necessary or beneficial to support investment in RNG, e.g. RPS-like requirement for RNG?

• Renewable Natural Gas - Power-to-Gas ('P2G'): What is the potential for P2G in Massachusetts? Can P2G deliver verifiable GHG emissions reductions? Have any of the gas distribution utilities investigated the use of hydrogen as a power source? What considerations are there for scalability and associated operational costs? Is there infrastructure investment required to support the widescale use of P2G? What policy or legislative action would be necessary or beneficial to support investment in P2G?

The AG also asks if the LDCs can be engaged in providing more energy efficiency programs and services

"What is the viability of gas demand resource programs to meet or contribute to emission reduction goals? Are adjustments to current cost-effectiveness screening of energy efficiency programs required to allow for the implementation of a gas demand response program? Can targeted or incremental electrification offset certain future GSEP [Gas System Enhancement Plan] investment? Does the Department need to review and revise the energy efficiency delivery platform, including the structure of company earned performance incentives, to support achievement of the Commonwealth’s climate goals? Should incentive structures be revised to allow for targeted or incremental electrification," the AG asked, concerning energy efficiency